The consultation on the White Paper on EU Communication Policy is sincerely welcomed by PASOS (Policy Association for an Open Society), a network of 26 independent policy centres in 18 countries in Central and Eastern Europe and Central Asia (including a total of nine policy centres from seven EU member-states).

As the White Paper states, delivery of a communications policy is not sufficient in itself; it is essential to any communication policy that the EU should delivery an "effective policy programme". To do so, any communications policy should take into account not only the information needs of the wider public, but also the means of communication to distinct constituencies, namely national and local, and the common policy areas where national and intergovernmental debate can be improved through wider stakeholder involvement. In particular, PASOS urges the European Commission to move away from an "exclusive" approach of concerning itself with the image of the EU in its members, and instead to adopt a proactive, positive communications strategy to foster a policy dialogue about Europe in the World, in short the EU as a positive, responsible partner, working with its neighbours and beyond to promote and strengthen human rights, democracy, peace and stability, good governance, and economic and social development.

PASOS supports the idea that "communication should become an EU policy in its own right, at the service of the citizens". It should be a part of every action undertaken by national, regional, local and EU bodies, and an emphasis should be placed on jargon-free, accessible communications. However, before embarking on a Charter or a Code of Conduct on Communication, the necessity of this step should be carefully evaluated, as citizens expect action, not grand statements.

Modes of communication

1. PASOS welcomes the establishment of internal rules for national, regional, local and EU institutions, making communication with the people one of the tasks of any official working there. In this communication, public institutions on all levels should focus on the following principles:

a) Communication should extend debate around, and understanding of, a sense of a common European project and a shared desire to promote the common interests of all EU countries. There is often a substantial mismatch between the messages about the European Union and its policies, both in style and substance, as communicated by national politicians and national media, and as communicated by the European Commission, due to a lack of consensus around the synergies between the EU institutions and national governments. The call for incorporating European issues in the programmes of national political parties is a step in the right direction.

b) Balanced information, combining positive messages and admitting mistakes, should be an integral part of the communication. Organising communication trainings for EU and national officials would be an important step forward. The EU representative offices in the EU member-states should take on a more proactive role, staffed by experienced diplomatic officials and communications professionals, who can engage with national politicians and at the same time provide a high-level service to citizens, and other residents, of EU countries as a first point-of-contact with EU institutions and as a key resource for accessing decision-makers at the European Commission and other EU bodies.

c) Communication is a two-way street: citizens need to be well informed about what public institutions do; but they also need to know that their opinions are heard. Channels and resources for this communication are already in place: media and non-governmental institutions. Public officials can use these channels to monitor public opinion and public concerns, and can reply to them through the same channels: letters to the editors, op-ed articles, participating in online forums, etc. Public debates on the Eurobarometer poll results could be one way for citizens to see that their opinions are taken seriously.

2. PASOS urges the Commission to refrain from direct, "technical" translations of the products of EU-wide campaigns into all the official languages of the EU as such campaigns can be resource-intensive but ineffective. Communication channels and communication products should be carefully chosen depending on the goal of the communication, the target groups and the specific needs of the member-states or regions in question.

3. PASOS recommends the Commission to exercise caution before creating and financing new online forums and websites with a view to learning the opinions of citizens and other residents. Instead, the Commission should seek out and use the numerous already existing information channels that have an established reputation for policy dialogue and public debate. The EU, and public institutions on the national level, have lost the trust of many citizens and other residents because the EU has for years bombarded people with colourful pamphlets in a one-way communication flow, instead of addressing their complaints and concerns. As a result, the EU is currently not in a position to expect citizens to be responsive to EU-financed online forums. The EU should recognise and use the information channels and opinion leaders that the people trust in - media and non-governmental organisations - as these can sustain debate and civic engagement in a more effectively, locally driven manner.

4. The European Active Citizenship programmes are welcome, but the focus on "citizens" in EU communications can introduce a layer of "exclusivity", if it neglects the rights and opinions of the millions of legitimate stakeholders who lack citizenship, in particular immigrant workers and refugees resident in the EU. A communications policy should strive to be as "inclusive" as possible.

5. PASOS welcomes the adoption of the proposed Citizens for Europe programme that would enable non-governmental organisations to organise public debates on European issues on a regular basis. Adequate funding should be made available so that NGOs can have the opportunity to launch initiatives and proposals for projects aimed at involving more people in European processes so that an ever growing number of EU citizens feel that they are actually living, not just existing, in the EU, and so that debates have a public advocacy element, enabling national policy reforms to be influenced by civil society input and public participation.

6. One way to get citizens more involved is by targeting the younger generation through teaching courses about the EU at schools, and also the adult population through courses within the framework of continuing education, in a balanced format setting the EU in a historical context. PASOS recommends an evaluation of the necessity and goals of such teaching, starting with an exchange of best practices in current curricula and courses.

Policy dialogue on Europe in the World

Any communications strategy requires a core message, as well as media of communication and message-delivery. To promote the notion of the EU not as an "insular" and "exclusive" club, neither Brussels-centric nor divisively cloaked in so-called "European values" (an approach that can alienate many ethnic and religious minorities within and beyond the EU's borders), it is necessary instead to promote a positive, inclusive and outward-looking vision of Europe, addressing Europe's place in the world as a responsible and positive force, both in soft and hard power, engaging with its neighbours as equal partners in the quest for common security, stability and prosperity.

PASOS recommends the following initiatives towards this goal:

1. The European Commission should work with national governments, parliaments, independent think-tanks and the media to foster a policy debate on Europe?s place in the world, and how to activate a more concerted approach to promoting democracy and good governance both within the EU and outside the EU, how to forge together a common foreign and security policy with a strong focus on democratisation, conflict resolution and promotion of human rights and civic participation, particularly in the former Soviet bloc, especially Belarus, Ukraine, Russia, the Caucasus, South-East Europe, and Central Asia.

2. The EU's communications policies not only need to be less Brussels-centric (particularly in terms of outreach to civil society organisations), but in addition engagement with public advocacy groups from civil society should focus on trans-national policy dialogue between non-governmental actors. This dialogue should not be restricted to stakeholders within the EU, but also with civil society and research institutions in other countries, in particular the southern and eastern neighbours of the EU. External perspectives on the EU must be addressed by any communications strategy. In this respect, PASOS welcomes the planned series of "stakeholder forums", and urges the Commission to view such events as far more than just informing citizens about the EU institutions, but as a major opportunity to engage in a wide-ranging debate in key policy areas affecting the EU and its place in the world.

To this end, PASOS urges the Commission to initiate a series of policy dialogue events on Europe in the World - examining democratic assistance, donor aid policies, mechanisms and tools to secure conflict resolution and promote regional stability, energy security, and other strategic questions facing the EU today. This debate lies at the core of an understanding of the EU, its future trajectory, and perceptions both within and beyond its borders.

This submission is endorsed by the following members of PASOS (Policy Association for an Open Society):